Chainstack Sanctions Compliance Policy

Disclaimer

Nothing in this Policy shall be construed as creating any obligation on Chainstack to monitor all customer activities or conduct ongoing sanctions screening beyond what Chainstack reasonably determines is appropriate based on its risk-based compliance program, applicable law and its contractual obligations.

1. Purpose

Chainstack is committed to conducting its business in compliance with applicable economic sanctions and export control laws and regulations.

This Policy establishes a risk-based framework designed to prevent the use of Chainstack Services in connection with sanctioned persons, restricted jurisdictions, sanctions evasion, or other prohibited activities.

2. Scope

This Policy applies to:

• Chainstack and its affiliates;
• all employees, officers, directors, and contractors;
• customers, partners, resellers, vendors, and other counterparties;
• all products and services provided by Chainstack.

3. Applicable Sanctions Regimes

Chainstack seeks to comply with sanctions and export control laws applicable to its operations, including those administered by:

• the United Nations;
• Singapore;
• the European Union;
• the United Kingdom;
• the United States; and
• other competent authorities where legally applicable.

4. Prohibited Persons and Jurisdictions

Chainstack does not knowingly provide services to:

• persons or entities designated under applicable sanctions programs;
• entities owned or controlled by sanctioned persons;
• persons acting on behalf of sanctioned persons;
• persons, entities, or activities where providing the Services would be prohibited under applicable sanctions or export control laws.

5. Prohibited Activities

Customers may not use the Services:

• in violation of applicable sanctions laws or regulations;
• to facilitate sanctions evasion;
• to provide services to sanctioned persons;
• to engage in transactions prohibited by applicable sanctions laws;
• in connection with weapons proliferation, terrorist financing, or other unlawful activities prohibited by applicable law.

6. Compliance Controls

Chainstack may implement reasonable sanctions compliance measures, including:

• sanctions screening;
• geographic restrictions;
• requests for additional information or documentation where reasonably necessary;
• investigation of sanctions-related concerns;
• monitoring for sanctions-related risk indicators.

Chainstack may request additional information reasonably necessary to assess sanctions-related risks.

Customers are expected to cooperate with reasonable sanctions-related compliance requests, including providing information or documentation reasonably requested by Chainstack to assess compliance with applicable sanctions or export control laws.

7. Suspension and Termination

Chainstack may suspend, restrict, or terminate access to Services if it reasonably believes that:

• continued provision of Services may violate applicable sanctions laws;
• a customer has provided inaccurate or misleading sanctions-related information;
• a customer is engaged in prohibited activities;
• continued provision of Services may expose Chainstack to legal, regulatory, commercial, or reputational risk.

Chainstack may also request additional information from a customer before deciding whether to suspend or terminate access to the Services.

8. Reporting and Escalation

Potential sanctions concerns shall be reviewed by designated legal, compliance, or management personnel. Where appropriate, Chainstack may consult external legal counsel or compliance advisors.

Chainstack may investigate sanctions-related concerns and cooperate with competent authorities where required by law.

9. Recordkeeping

Chainstack may maintain records relating to sanctions reviews, investigations, and compliance activities in accordance with applicable legal, regulatory and business requirements.

10. Policy Review

This Policy may be updated periodically to reflect legal, regulatory, operational, or business developments.

This Policy is intended solely to provide general guidance regarding Chainstack’s sanctions compliance program. It does not create any contractual or other legal rights in favor of any third party and does not limit or modify Chainstack’s rights under its Terms of Service, customer agreements, or applicable law.